Recognises high-risk processing with no DPIA

S-406 · Skill knobit · Activity: Record processing activities and assess privacy impact · Competence: Data security

Profiling or automated decisions with legal effect and no DPIA.

Can AI do this?

AI does this well Most of the tested AI models master this. 4 of 4 models in the current benchmark master it.

Model	Tier	Probability of mastery	Status
gemini-4-argon	Flagship	95%	Mastered
gemini-3.5-flash-lite	Low cost	95%	Mastered
gpt-6-luna	Low cost	95%	Mastered
claude-haiku-5-5	Low cost	95%	Mastered

Mastered means a probability of at least 90% that the model has this knobit, estimated from its graded answers. “Not shown” means the answers do not settle it either way. How the models are tested.

What it looks like in practice

Expected result: The processing and the DPIA it needs

How it is assessed: Flags the deficient case and passes the acceptable one. Deficient: PA-003 automated credit scoring, dpia: null Acceptable: DPIA DI-001 with DPO advice

Also known as: High-risk processing with no DPIA

Related knobits

Builds on

S-453 Explains DPIA triggers and automated decisions

Usually followed by

S-433 Proposes a DPIA with Art. 22 safeguards for automated decisions

All 19 knobits of Record processing activities and assess privacy impact.

Source: Review checklist 04-privacy, row 6 (GDPR Art. 35; EDPB)